Sixto Jorge Diaz-Colon v. United States
DueProcess FifthAmendment Punishment HabeasCorpus ClassAction
Whether an appellate court violates due process by dismissing an appeal based solely on procedural deficiencies without addressing substantial constitutional claims or providing an opportunity to correct such deficiencies
QUESTIONS PRESENTED I. WHETHER AN APPELLATE COURT VIOLATES THE DUE PROCESS CLAUSE OF THE FIFTH AMENDMENT BY DISMISSING AN APPEAL BASED SOLELY ON PROCEDURAL DEFICIENCIES, SUCH AS NON-COMPLIANCE WITH LOCAL COURT RULES, WITHOUT ADDRESSING SUBSTANTIAL CONSTITUTIONAL CLAIMS NOR PROVIDING PETITIONER WITH AN OPPORTUNITY TO CORRECT THE PROCEDURAL DEFICIENCY, THEREBY DENYING MEANINGFUL APPELLATE REVIEW. Il. WHETHER THE DENIAL OF BAIL PENDING APPEAL, COMBINED WITH DISMISSAL OF THE APPEAL FOR PROCEDURAL NON-COMPLIANCE, CONSTITUTES EXCESSIVE BAIL IN VIOLATION OF THE EIGHTH AMENDMENT AND INFRINGES UPON THE STATUTORY RIGHTS TO BAIL UNDER 18 U.S.C. § 3143(B). Ill. WHETHER PROCEDURAL RULES, SUCH AS THE FIRST CIRCUIT'S LOCAL RULE 32.4, REQUIRING COMPLIANCE WITH WORD LIMITS, FORMATTING, AND AUTHORIZATION FOR OVERSIZED BRIEFS, CAN PRECLUDE SUBSTANTIVE APPELLATE REVIEW OF SIGNIFICANT CONSTITUTIONAL AND STATUTORY CLAIMS, CONTRARY TO SUPREME COURT PRECEDENT AFFIRMING THAT CONSTITUTIONAL RIGHTS CANNOT BE SUBORDINATED TO PROCEDURAL TECHNICALITIES (STINSON V. UNITED STATES, 508 U.S. 36 (1993); MARBURY V. MADISON, 5 U.S. 137 (1803). IV. WHETHER PROCEDURAL RULES CAN OVERRIDE SUBSTANTIVE CONSTITUTIONAL RIGHTS, SUCH AS THE SIXTH AMENDMENT'S GUARANTEE OF A FAIR TRIAL OR PREVENT APPELLATE REVIEW OF UNRESOLVED STATUTORY CLAIMS RELATED TO BAIL PENDING APPEAL UNDER 18 U.S.C. § 3143(B). V. SHOULD THIS COURT EXERCISE ITS SUPERVISORY AUTHORITY TO ENSURE UNIFORMITY THAT CONSTITUTIONAL RIGHTS AND STATUTORY GUARANTEES, SUCH AS THE RIGHT TO BAIL PENDING APPEAL AND MEANINGFUL APPELLATE REVIEW, ARE ADJUDICATED ON THEIR MERITS AND NOT DISMISSED SOLELY FOR PROCEDURAL NON-COMPLIANCE? lll The legal issues arise from a common series of facts, so they are presented conjunctively in order to avoid repetitive arguments.